Episode 85
Opinion Summary: Martin v. United States | Date Decided: 6/12/25 | Case No. 24–362
Opinion Summary: Martin v. United States | Date Decided: 6/12/25 | Case No. 24–362
Link to Docket: Here.
Background:
Petitioners are the innocent victims of a wrong-house raid conducted by an FBI SWAT team in Atlanta, Georgia. Seeking a remedy for torts committed against them, Petitioners brought a cause of action against the United States under the Federal Tort Claims Act. In its opinion below, the Eleventh Circuit held that all of Petitioners' FTCA claims are barred by sovereign immunity supplied either through the Constitution's Supremacy Clause or the FTCA's discretionary-function exception. In one or more ways, the opinion below conflicts with decisions from every other circuit.
Questions Presented:
- Whether the Constitution's Supremacy Clause bars claims under the FTCA-a federal statute enacted by Congress-when the negligent or wrongful acts of federal employees have some nexus with furthering federal policy and can reasonably be characterized as complying with the full range of federal law.
- Whether the FTCA's discretionary-function exception bars claims for torts arising from wrong-house raids and similar negligent or wrongful acts by federal employees.
Holdings:
- The law enforcement proviso in Section 2680(h) overrides only the intentional-tort exception in that subsection, not the discretionary-function exception or other exceptions throughout Section 2680.
- The Supremacy Clause does not afford the United States a defense in FTCA suits.
- On remand, the Eleventh Circuit should consider whether subsection (a)'s discretionary-function exception bars either the plaintiffs' negligent- or intentional-tort claims—undertaking that assessment without reference to the mistaken view that the law enforcement proviso applies to subsection (a).
Result: Vacated and remanded.
Voting Breakdown: 9-0. Justice Gorsuch delivered the opinion for a unanimous Court. Justice Sotomayor filed a concurring opinion, in which Justice Jackson joined.
Link to Opinion: Here.
Oral Advocates:
- For Petitioners: Patrick M. Jaicomo
- For Respondents: Frederick Liu, Assistant to the Solicitor General
- For Court-Appointed Amicus Curiae in Support of Judgment Below on Question 1: Christopher E. Mills
Website Link to Oral Argument: Here.
Apple Podcast Link to Oral Argument: Here.
Timestamps: